The Ministry of Economy announced this Wednesday a series of modifications to the Fiscal Innocence Bill, which seeks to expand the scope of capital amnesty. The changes, presented by Minister Luis Caputo and the Secretary of Legal and Technical Affairs of the Presidency, María Ibarzabal Murphy, aim to simplify the regime and provide greater guarantees to taxpayers.
What the original bill established and what changes
The original bill, which had already been approved, established three conditions to access the simplified sworn declaration regime: annual income not exceeding one billion pesos, total assets not exceeding ten billion pesos, and not being considered a «Large Taxpayer» according to ARCA regulations. The new proposal eliminates these restrictions, allowing all resident individuals and undivided estates to adhere, with the caveat that «Large Taxpayers» may use the simplified modality but without enjoying the benefits of presumptions and liberating effects.
Another relevant change concerns when the tax authority can break the presumption of accuracy of declarations. Currently, if ARCA’s challenge results in an increase of 15% or more over what was declared, the presumption automatically falls. The bill introduces a minimum threshold: even if the 15% is exceeded, the presumption is maintained if the nominal difference does not reach the equivalent of 5% of the evasion amount provided for in the Criminal Tax Law, that is, five million pesos. Additionally, if ARCA detects a discrepancy, the taxpayer may file a corrective sworn declaration and pay the difference plus interest within a period of up to 15 business days.
The context of informality and dollars outside the system
Caputo explained that the initiative responds to a process of growing informality generated by years of high tax pressure, fiscal deficit, monetary issuance, inflation, and exchange restrictions. He noted that although dollar deposits in the financial system are at record levels close to 40 billion dollars, there is an amount more than four times that figure in savings kept outside the banking circuit. The formalization of these resources, according to the minister, represents a benefit for both citizens and economic development.
Value module: comparison between the current regime and the bill
| Aspect | Current regime | Modification bill |
|---|---|---|
| Subjects that can adhere to the simplified regime | Persons with income ≤ $1,000,000,000 annual, assets ≤ $10,000,000,000, and not being a «Large Taxpayer» | All resident individuals and undivided estates, without income or asset limits. «Large Taxpayers» can adhere but without full benefits. |
| Breaking the presumption of accuracy | If ARCA’s challenge exceeds 15% of declared, the presumption automatically falls. | The presumption is maintained if the nominal difference does not exceed $5,000,000 (equivalent to 5% of the evasion amount). |
| Deadline to rectify and pay | Not specified in the material. | Up to 15 business days from notification of the official determination. |
| Reimbursement of contributions if the taxpayer wins a claim | Not specified in the material. | ARCA must reimburse the contributions paid with interest within a maximum period of 45 business days from notification of the final resolution. |
Note: The values in pesos correspond to the amounts mentioned in the official announcement. No conversion to other currencies was made because the material does not provide exchange rates or exact dates to do so.
Documents and open questions
- Official document: Announcement of the Ministry of Economy of June 12, 2025 (primary source). It establishes the proposed changes to the Fiscal Innocence Bill. It does not establish the full text of the bill or the detailed rationale.
- Article from La Izquierda Diario (secondary source): It is not directly related to the amnesty topic; it deals with the Conquest of the Desert and land distribution in Patagonia. It does not provide information on the Fiscal Innocence Law.
Open questions: What is the exact text of the bill? When will it be sent to Congress? What fiscal impact is estimated? How will the simplified modality for Large Taxpayers be implemented? What happens to cases already in progress?
What to follow
It is advisable to follow the parliamentary discussion of the bill and ARCA’s regulations, as well as official estimates of the amount of assets that could be amnestied. It is also relevant to observe whether additional changes are incorporated during the legislative debate.
Fuentes consultadas
- La Izquierda Diario
- Argentina.gob.ar Fuente primaria
El Sereno contrastó las fuentes enlazadas y añadió contexto, comparación o análisis documental. Las fuentes primarias están identificadas. La nota no se presenta como investigación de campo ni como entrevista propia, salvo indicación expresa.
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